The information
collection in this reproposed rule is not approved at this time.
The agency appears to seriously understate the burden of this
collection. For example, the agency cites state regulator
complaints that local offices are often poorly organized and
inefficiently run, hindering examination. However, in the estimates
of the costs of the rule, the agency states that creation of the
records is already an accepted business practice and required by
SROs. This statement raises doubts about the expected impact of
this additional rule. In addition, the agency appears to omit the
additional costs required by the increased post traffic required by
the rule, (about 6.6 million dollars based on 20 million records a
year, .66 million dollars for 2 million responses) and any costs
associated with modifying computer systems to generate the
additional records.
Inventory as of this Action
Requested
Previously Approved
03/31/1999
12/31/2001
06/30/1999
7,769
0
7,769
1,941,062
0
0
0
0
0
The Commission is reproposing
amendments to Rule 17a-3 which would require broker-dealers to keep
certain records. The records would be important for regulatory
investigations and examinations and for the protection of the
public.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.